MATRIZ DE EVALUACIÓN DEL CUMPLIMIENTO DE LA NORMATIVA AMBIENTAL

Incoherent policy making can lead to policy paradoxes and these can occur both within an implementation process and in concurrent policy implementation in the same environment. Many examples can be drawn from the literature one such relates to funding e-learning and school management policy, where the government in the UK proposals proposed to centrally manage funding to promote e-learning whilst on the other hand advocating local decision taking and making within schools (Mee, 2007). Policy paradoxes are described within the literature as evolving from the competing and the contextually situated nature of policy implementation i.e. that policy does not exist in a vacuum and that a variety of factors/pressures impact on policy at any time during the implementation process. Maintaining a coherent or rational policy from policy formulation and implementation is extremely difficult. AFI implementation provides insight into policy paradoxes within that policy process. Some paradoxes are identified and contextualised by participants. These findings include the identification of forces both internally and externally which led to the perceived shifting within the process of previous policy positions, objectives and implementation practices and in some cases to policy paradoxes. Policy implementation is influenced by a variety of forces which influence policy as it moves up and down the policy staircase. Forces are not always applied in a neat linear, rational or incremental fashion and they are not always directly linked to

specific or individual implementation processes. This can lead to policy paradoxes and implementation gaps across and in between levels on the implementation staircase. The policy objective of flexible learning was an expressed element of the AFI precepts (DCU, 2007b). Accounts of AFI participants at institutional level, however, indicate that the interpretation of the type of flexibility and hence the objective of policy was contested i.e. between academic and administrative modularisation (this would later emerge within the process as curricular and temporal flexibility). The lack of clarity as to which type of flexibility to be achieved is identified within participants accounts as to leading them to interpret various aspects of the AFI innovation bundle in different ways (ADVISOR01, 2009 , 2010 , ADVISOR02, 2010 , AFIMGT01, 2010 , AFIMGT02, 2009 , AFIMGT04, 2009 , 2010 , UTL06, 2010).

Within this case of AFI implementation participant data identified such occurrences; these occurrences were associated with the funding policy and resource grant allocation model of the HEA. As a dominant understanding of flexibility to be supported within the AFI process at institutional level emerged within accounts, the influence of the external funding from higher up the implementation staircase was seen as applying particular pressure on this objective. This pressure was identified as restricting the institution’s potential to realise flexibility during implementation (ADVISOR01, 2009). To implement AFI’s version of flexibility (in relation to the principle of progression where a reduced or increased number of credits which students could complete each year) a specific and revolutionary change of the funding model of the HEA was identified within participant accounts to be needed. The funding model for undergraduate students would need to change from the completion of 60 credits each year for up to three/four year cycle, to a model which linked funding to actual credits taken over X amount of years to a maximum of 180- 240 credits. Within national policy documents it appears that a coherent policy

environment was supported. The Department of Education and Science indicated to the universities that funding would be conditional on the alignment of awards with the NFQ (IUA, 2006). Furthermore, in 2008, the HEA developed a set of strategic goals for the Higher Education sector as part of a proposed process to evaluate the performance and funding of institutions (HEA, 2008a). A shift to a learning outcomes approach was described as a key element for institutions to improve the quality of teaching and learning as part of an performance assessment (ibid) which would provide:

flexibility in provision, offering multiple opportunities for educational progress through mechanisms such as modularisation, part-time study, distance learning, and e-learning thereby bringing reality to the concept of lifelong learning

(HEA, 2008:12)

The funding model, however, did not change in practice during the implementation of AFI in spite of the rhetoric of policy documents. This led to a policy paradox between the institutional and national levels, but also at the national level. AFI proposed a flexible funding model, whilst the national funding model was devised specifically to fund full-time undergraduate students. The influence of this paradox within the institutional context led and necessitated an implementation gap at the institutional level, as the institution could not adopt an approach to flexibility which would reduce or compromise the institution’s budget.

This implementation gap was identified as influencing the type of flexibility that AFI could explore by participants:

…we were looking at was this whole idea of flexibility and how that would be funded, bearing in mind how the government funds but then how the government funds is currently under review and they won’t give us a definitive answer at the moment and certainly if you were back again listening to well we’ve have fees from September 12 months again, so you know HEA aren’t prepared to commit. At the moment, officially you are funded for your, a four year undergraduate primary degree, that’s what you’re funded for. If you take five years to do it, by right you should be paying the last year yourself. If you do it in three years you know, there’s no clarity and that’s why we did ask about horizons, how they manage that in UCD where you can take a minimum of fifty to a maximum of seventy credits per year and it’s done on a nod and a wink we were told and I said I’m not developing a policy on a nod and a wink, either I know or I don’t know. And that’s it, we did develop a number of models and we costed them but that’s as far as we can go until I know is the government prepared to fund a student that way

(AFIMGT03, 2010)

A further policy pressure which put pressure on institutional implementation and the notion of flexibility, was the HEA’s Strategic Innovation Fund (SIF) process in 2008. Within the theme unanticipated consequences to purposive actions, reference is made to the SIF funding calling which was sought to fund the implementation of AFI. The university sought to acquire a new Management Information System (MIS) which in some participants’ accounts at institutional level was pivotal to the implementation of full flexibility13 (AFIMGT03, 2009 , AFIMGT04, 2009 , AFIMGT05,

2009). Other institutional level accounts avert to the fluid concept of flexibility and the possibility of current systems to support this notion even when the outcome of the SIF MIS funding was confirmed (ADVISOR01, 2011 , ADVISOR02, 2010 , AFIMGT09, 2011). The funding for the MIS component of SIF reportedly did not materialise, although the university had received positive feedback from the national evaluation panel (DCU, 2008a). Accounts from official university documentation document an awareness of the influence that the contingent factors of the absence

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of SIF MIS funding and the required change in the HEA funding model (DCU, 2007a) would have on the scale of the reforms being implemented. These findings support policy being made and re-made in response to these external pressures. Policy implementation within the institution was not only responsive to its own institutional environment but also to the contexts and complexities of policy higher up on the implementation staircase. The process of the adoption of the learning outcomes approach can also be considered as supporting a policy paradox with regards to providing increased flexibility within the system for students. One feature of this paradox bore out during the writing of the university’s revised Marks and Standards, a sub-project of AFI. Within accounts of AFI Executive members the new version of Marks and Standards that were written were viewed as an interim step to pave the ground for full flexibility.

However, this account also acknowledges that the interim Marks and Standards were closely aligned to Bologna credit considerations. The interpretation of workload associated to credits within the European Credits Transfer System which was adopted within Marks and Standards equalled one credit with twenty-five hours of workload. Using these calculations a maximum number of calculations was set out for an undergraduate student at 75 credits based on the university’s calendar. Adopting such a mechanism within the university’s standards and regulation further limited the type of flexibility that the university could implement into the future. Even if temporal flexibility became the de-facto meaning of flexibility which emerged or was supported within the process, adopting this approach was in essence practically contradictory to the accounts within both official documentation and interview data of institutional level participants.

Within these accounts they identify concepts of life-long learning, changing student engagement patterns etc. as leading the objectives if AFI to achieve as this formula limited accelerated pathway through degrees:

• fostering flexible approaches to programme development

• widening student choice - both in terms of curriculum and mode of study (DCU, 2007b:1)

As previously discussed within this theme, this restriction facilitated the current practice with relation to maintain an overarching programmatic paradigm within the system and resisted academic modularisation or the so-called “kitchen sink degree”. The findings presented in this theme of incoherent policy making are indicative of an ideographic notion of policy which rejects linear, incremental and rational views of the policy process. They illustrate at the institutional level the dynamic environment in which policy was encoded and support the notion of policy in motion. AFI policy and its interpretation by participants did not remain static. Participants in their accounts draw on the complexity of the policy process and describe forces from various levels of the implementation staircase which impacted the policy process.